ML20309B055
| ML20309B055 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 11/03/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR27447 | |
| Download: ML20309B055 (8) | |
Text
From:
Diane Tasian <Diane@thetasians.com>
Sent:
Tuesday, November 3, 2020 3:49 PM To:
WCS_CISFEIS Resource Cc:
Diane Tasian
Subject:
[External_Sender] Docket ID: NRC-2016-0231-0342 Docket ID: NRC-2016-0231-0342 RE: The proposed Nuclear Regulatory Commission licensing of Consolidated Interim Storage Facility (CISF) for spent nuclear fuel (SNF) and greater than Class C (GTCC) waste at Waste Control Specialists existing low-level radioactive waste site in Andrews County, Texas.
Dear Nuclear Regulatory Commission,
Please provide public meetings in major Texas cities, beginning 60 days after the Covid crisis is over to address the health impacts of transportation and storage of high-level nuclear waste.
Issues the League of Women Voters of Dallas find most pressing are:
(1) The EIS does not study the impact of a serious accident in which radioactive material escapes from a container. The magnitude of difference between the low level waste that is currently allowed and the high level waste that the NRC is contemplating allowing to pass through our cities is incredibly serious.
(2) The timing of this application. Why is this being requested now, when existing sites are allowed to store materials for 60 years?
(3) The proximity of the rail lines through the center of of our cities. Below please see the map of Dallas with rail lines that would be used traveling from the east. These lines go directly through Mesquite, Dallas, and Grand Prairie. As Dallas works to stabilize, preserve, and develop neighborhoods near downtown and continues to develop housing near and in downtown the number of people that would be affected by a spill or accident continues to rise.
(4) The addition of hundreds of metric tons of high-level radioactive waste stored anywhere in the great state of Texas.
This map shows where the existing nuclear plants are. Why should Texas solve their storage problems?
Source: https://commons.wikimedia.org/wiki/File:US_Nuclear_Power_Plant_Status_9-2013.PNG The next map, a detail from a statewide railroad map, shows Dallas and Tarrant counties. The red lines show the Union Pacific Railway path:
Source: http://ftp.dot.state.tx.us/pub/txdot-info/tpp/maps/2016-railroad.pdf The distance from the rail line that is most at risk of exposure to radiation if the containers are leaking or if trains stop for any length of time is 1/2 mile. The amount of exposure from routine emissions for a
person standing about 6 feet from a rail car with encased high-level radioactive waste is less than a chest x-ray.
This is a description of the Union Pacific railway path through Dallas County from east to west:
Scyene Rd crossing county line to Berry Rd: Union Pacific rail line enters Dallas County from the east adjacent to E Scyene Road. Agricultural land is along the north side of the rail line for about 3 1/2 miles to Hwy 352. Along the south side is the Mesquite Metro Airport and agricultural to Clay. 3,4 Scyene from Berry to I635 (Mesquite city center): From Berry along the north side of the rail line there is primarily commercial/industrial development. There is a small section of residential east of Belt Line on the north side. The Mesquite City Hall, Chamber of Commerce, and main post office are all about 1/2 mile north of the rail line. Medical Center of Mesquite is about a mile north of the rail line.3,4 Along the south side of the rail line residential is within a half mile. After Clay the residential areas are right up against Scyene Rd and the rail line. After the Hwy 352 intersection the city of Mesquite occurs on both sides of the rail right of way (ROW) and Scyene Rd. Mesquite High School and Hanby Stadium are 2 blocks from the rail ROW. Galloway Park is within 1/2 mile of the ROW.3,4 I635 to Lawnview and the Southern Pacific rail line: Along the north side of the ROW there is commercial/industrial development. Along the south side of the ROW there is residential. When it crosses S Town East Blvd development resumes as commercial/industrial on both sides of the railway. Skyline High School is 2 blocks north of the rail ROW. The Urbandale/Parkdale neighborhood is directly south of the rail line. The Tri-City Health Center is about a mile south of the rail line. Eest of the Parkdale Lake the rail line merges south with the Southern Pacific rail line.
Proceeding southwest along the Southern Pacific rail line to Hwy 310 and then north west to Commerce St.: Along the first half of this section the residential area of South Dallas is to the north west side of the rail line. The Great Trinity Forest is on the south east side. Wahoo Park, Craft Park, Genera Park Nelson Park, Lincoln High School and their neighborhoods are within 1/2 mil of the rail line. Along the second half South Dallas and downtown Dallas are on the northeast side of the ROW and the Trinity River portion of the Great Trinity Forest is on the southwest side. This brings the rail ROW right through the edge of the urban core. Forest Park, the Cedars, the Government District, the Convention District, the Omni Dallas Hotel, Reunion District, West End Historical District, the JFK Memorial are all within 1/2 mile of the rail line.2,3,4 At Commerce Street the rail line turns west to become Union Pacific line, crosses the Trinity River, and goes through the heart of West Dallas. Due to recent construction this area is now being covered with multi-family residential along both sides of the ROW.3,4 Just before Loop 12 and I30 the line dips southwest across wooded and agricultural land until it bends to go due west at the north end of Hensly Field, which is slated to be redeveloped in the near future, and thence through the heart of Grand Prairie. Mockingbird Park, Live Oak Park, Crockett Park, Grand Prairie City Hall, Grand Prairie Chamber of Commerce, Grand Prairie Theater and 6 Flags Mall are all within 1/2 mile of the rail line.3,4 Sources:
- 1. https://www.txdot.gov/inside-txdot/division/transportation-planning/railroad.html, http://ftp.dot.state.tx.us/pub/txdot-info/tpp/maps/2016-railroad.pdf
- 2. https://dallascityhall.com/government/Council%20Meeting%20Documents/msis_6_great-trinity-forest-resolution_memo_042219.pdf. Page 7 is a map of the boundary of the Great Trinity Forest.
- 3. DeLorme Atlas & Gazetteer; Texas, 2009, pages 111 - 115.
- 4. iPhone map application.
A. Resolutions concerning nuclear waste transport:
Bexar County Feb. 21, 2017. http://nuclearactive.org/wp-content/uploads/2017/04/Bexar-County-Resolution-Feb-21-2017-1.pdf Dallas County Apr. 4, 2017: http://nonuclearwasteaqui.org/downloads/Dallas_resolution.pdf City of San Antonio:
https://webapp9.sanantonio.gov/ArchiveSearch/Viewer2.aspx?Id={E1F1DE69-785B-4DB5-B56A-C71497C4A9F2}&DocTitle=Resolution%202017-03 0016R&PageNo=&TotalPages=&MimeType=application/pdf&RelatedDocs=
B. Gov. Greg Abbot letter: https://www.eenews.net/assets/2020/10/01/document_daily_03.pdf urges opposition.
Public Process Must Improve The public should be informed about the health and safety risks as well as financial liabilities to Texans and have opportunities to comment, but the democratic process has been woefully inadequate so far.
The NRC has held only one public meeting on this important issue in Texas. The February 15, 2017, meeting in Andrews was too far away for many Texans to attend. Some meetings were held online, but none were ever held in the many Texas cities that could be directly impacted by high-level radioactive waste transport. By contrast, for the Yucca Mountain repository, over two dozen meetings were held throughout the nation.
Permanent disposal of high-level radioactive waste must keep the waste isolated from living things for a million years, but the Yucca Mountain location in Nevada was not viable, and the project was canceled. The band-aid interim style approach to store the deadly waste in Texas and/or News Mexico, Consolidated Interim Storage (CIS), could turn into dangerous de-facto permanent disposal at sites never designed for the long term.
Hardened on-site storage (HOSS) is the least risky approach to radioactive waste at this time. With HOSS, the waste must be safeguarded as close to the site of generation as possible, and transport should be minimized. Storage system designs should have projected releases low enough that an attack on the storage systems would be unattractive as a terrorist target. Research must continue for viable permanent disposal.
Please provide public meetings in major Texas cities, beginning 60 days after the Covid crisis is over.
Your help is greatly needed to protect public health, the environment, and the democratic process with transparency, accountability, and justice for all.
Sincerely yours, Diane Tasian League of Women Voters of Dallas President 2019-2021 president@lwvdallas.org lwvdallas@sbcglobal.net (214) 688-4125 www.lwvdallas.org
Empowering Voters. Defending Democracy.
Federal Register Notice:
85FR27447 Comment Number:
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